UHLC Prof Bret Wells urges overhaul of foreign tax credits for US companies

UHLC Associate Professor Bret Wells, second from left, discussed foreign tax credits recently at ExxonMobil's quarterly "Lunch & Learn" speaker series. Among the audience were Jim Roach,, manager of planning and finance in Exxon's tax department, left, Denney Wright, senior tax counsel in Exxon's  global training and development office who also teaches Oil and Gas Taxation at the Law Center as an adjunct professor, UHLC Professor William Streng, and Dean Leonard M. Baynes.

Oct. 20, 2015 – University of Houston Law Center Associate Professor Bret Wells, a tax law and oil and gas specialist, spoke recently on tax credits at a "Lunch & Learn" session hosted by the tax department of ExxonMobil at its new facility in the Woodlands.

Wells, recently named director of the Law Center's Environment, Energy & Natural Resources Center, spoke on his paper, "The Foreign Tax Credit War," that will be published next year in the BYU Law Review. He also will present the paper next spring at an International Tax Symposium hosted by BYU Law School.

Foreign tax credit relief is provided under U.S. tax law to mitigate against the risk of international double taxation that could arise whenever both foreign governments and the U.S. seek to simultaneously tax the overseas operations of U.S. companies.

Wells calls for an overhaul of the current system, which he calls a "byzantine structure of staggering complexity." He argues that significant simplification is needed and can be achieved without diminishing the effectiveness of the current law's disallowance of strategies that artificially generate excessive amounts of foreign tax credit relief.

The presentation was viewed by approximately 150 ExxonMobil tax professionals in five locations across the ExxonMobil Tax network in the U.S. and abroad, and will be posted on the ExxonMobil Global Training Network. Wells was accompanied by fellow tax Professor William Streng and Law Center Dean Leonard M. Baynes.

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